Specialty Certification

Objectives of the CSMBE Certification Program:

• To achieve recognition of the advanced skill level required for the examination of large and complex Money Service Businesses and their compliance with state and federal laws and regulations applicable to regulated licensees.  Money Service Businesses include money transmitters; currency dealers/exchangers; check cashers; and issuers, sellers or redeemers of traveler’s checks, money orders or stored value products.
• To promote continuing education in the Money Service Business area of the regulation.
• To emphasize the need for professionalism and continuing advancement of Money Service Business examination professionals given the specialized skills and knowledge necessary to adequately supervise this area.
• To enhance and maintain the quality of job performance and skill level of Money Service Business Senior Examiners.

Candidates for CSMBE designation must provide evidence of all of the following:

• Completion of a minimum of 3 years’ experience of on-the-job examination of money service businesses including on and off-site reviews of operational processes, review for compliance with state and federal consumer compliance regulations, review of compliance with Bank Secrecy Act and Anti-Money Laundering regulations, and knowledge of established examination procedures and process. In addition, experience serving as the lead EIC or State Lead on at least four full-scope examinations in one year. These examinations should include non-bank financial institution/licensee examination analysis, leading a multi-state/agency examination team and completing the final report of examination. This examination should include review for compliance with state and federal laws and regulations including Bank Secrecy Act / Anti-Money Laundering compliance as it relates to these MSBs, as well as operational and financial analysis of the licensee.
• Satisfactory completion of the following course offerings or their equivalent:
  • Course requirements for the CMBE designation, and
  • MTRA Intermediate School, and
  • Day One BSA
• Attestation of successful job performance and mastery of appropriate job-related skills by a superior within the candidate's organization. All attestations shall be considered final once signed. A defined response form that outlines the necessary and appropriate skills will support attestation as to a candidate’s skill. A high degree of reliance is placed on the attestation forms provided by the applicant’s supervisor when granting certification. For that reason, the individual signing the attestation form should be familiar with the applicant’s experience, performance, and skills and abilities, and should be confident that the applicant meets all the requirements as noted on the form.

The attestation form addresses the following categories:

TECHNICAL - Provides effective leadership and organization to the examination process:

• Effectively supervises personnel to ensure adherence to examination procedures and policies,
• Effectively organizes and delegates assignments on examination of larger multi-state licensees,
• Provides effective training for coworkers and others as appropriate or required,
• Monitors progress of assigned personnel to ensure accurate and timely completion of work,
• Effectively organizes and delegates assignments,
• Supervises, organizes, and effectively documents workpapers according to prescribed procedures,
• Effectively supervises and oversees the entire examination process,
• Awareness of SES.

CONCEPTUAL - Provides effective and accurate evaluation of the overall activities of multi-state licensees:

• Effectively demonstrates knowledge of policies, procedures, laws, rules and regulations,
• Effectively follows established examination procedures to collect and analyze data,
• Develops correct conclusions from collected data,
• Effectively reviews reports of examination for accuracy, content, conclusions, and proper grammar,
• Effectively evaluates and adjusts scope of examination as each situation requires.
• Need to be familiar with the types of MSBs including:
  • Foreign currency exchanges
  • Check cashers
  • Sellers, issuers, or redeemers of traveler’s checks, money orders, prepaid cards, etc.
  • Remittance services
  • Post offices
  • Bill payment services
  • Peer-to-peer lending or equity-based crowdfunding platforms
  • Digital eCommerce and payment processors
  • Cryptocurrency exchanges (including fiat-to-crypto and vice-versa)
• Understands components of the MTRA work program: should be efficient in every tab and able to complete independently (with exception of IT, virtual currency, and foreign currency which can be completed with assistance) 
• Procedures for writing findings and reporting to lead state, Requests for Information; 
• Deeper understanding of emerging technologies, securities, cryptos, bond ratings; 
• Understanding financials and making sure the financials are certified, notarized; Understanding flow of funds.

LEGAL/COMPLIANCE - Effectively demonstrates knowledge of policies, procedures, laws, rules and regulations, both state and federal, related to Money Service Businesses (Money Transmitters).

HUMAN RELATIONS - Provides effective oral and written communications:

• Effectively and clearly communicates assignments to assisting personnel,
• Effectively and clearly communicates with licensee’s personnel to obtain information,
• Effectively and clearly communicates examination findings to licensee and supervisory personnel,
• Effectively prepares written comments which are accurate, grammatically correct, logically arranged, and factually support any conclusions drawn,
• Understand how to compose and edit a Report of Examination: put things in context, be clear and concise; ability to issue or finalize report as applicable
• Effectively conducts meetings with management and/or the boards of directors of licensees,
• Effectively coordinates examination planning and execution with other state and federal supervisory authorities.

Recertification

Every three years, participants will be required to provide evidence of the successful completion of a minimum of 40 continuing education hours (CEHs); at least seven CEHs must be completed each year. Examples of qualifying programs and activities are listed below. Other programs and activities submitted will be considered on a case-by-case basis.

The following courses and applicable offerings from providers would qualify as continuing education:

• CSBS BSA/AML Examiner School
• CSBS LEAD (Formerly Senior School)
• MTRA Annual Meeting & Examiner’s School
• NCUA Consumer Compliance Training
• Applicable portions of Annual Conferences or other seminars, not utilized for minimum certification requirements, of:
  • CSBS
  • NMLS
  • MTRA
  • NACARA
• FIS: Regulatory University
• Chainalysis
• LinkedIn Learning
• Anti-Money Laundering Workshop
• Cybersecurity Audit School
• Global Financial Markets Institute Classes
• Federal Financial Crime Enforcement Network
• Federal Deposit Insurance Corporation
• Internal Revenue Service
• Federal Reserve Board
• Association of Certified Anti-Money Laundering Specialists
• Association of Certified Fraud Examiners
• Association of Certified Financial Crime Specialists
• Bank Administration Institute
• Financial Service Centers of America Annual Conference
• Prepaid Card Expo